Clay v. Department of Treasury

Background

Thomas Clay, identified as a Texas state prisoner representing himself, filed a civil action against the Department of Treasury and other defendants. The court previously denied the case during its initial screening. Clay then filed a motion under Federal Rule of Civil Procedure 59(e), which permits a party to ask the court to alter or amend a judgment.

Clay sought court intervention concerning an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act. The opinion discusses an earlier decision stating that an economic impact payment could not be denied solely because a person was incarcerated, but that the earlier court did not decide whether particular incarcerated plaintiffs were owed payments. The opinion also states that the CARES Act deadline for making or allowing the payments was December 31, 2020, and that no more funds could be issued under that Act.

Legal standard

The court explained that a Rule 59(e) motion must be filed within 28 days after judgment. Reconsideration under that rule ordinarily requires newly discovered evidence, clear error by the court, or an intervening change in the law. Evidence is not newly discovered if it was available before the court’s ruling.

Court’s reasoning

The court found that Clay presented the same arguments he had made in his complaint. It concluded that he had not provided newly discovered evidence, shown clear error, or identified an intervening change in the law.

The court separately addressed Clay’s Equal Protection claim. It held that Clay had not shown that he was treated improperly differently from other similarly situated people. The fact that some inmates received economic impact payments while Clay did not, without more, was insufficient to establish an Equal Protection violation.

Disposition

The court denied Clay’s motion to alter or amend the judgment. The order was signed by United States District Judge Phyllis J. Hamilton and dated December 21, 2021.